Reopening of Assessment u/s 147 Challenged; Court Finds It a Change of Opinion, Not Permissible by Law.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 - deduction u/s 57 disallowed - AO has applied his mind and formed an opinion for allowance of this interest expenses while framing original assessment. Now, reopening on the very same issue tantamount to change of opinion which is not permissible in law. - AT....